ML20049J658

Amended Petition to Intervene in Proceeding & Request for Hearing.Affidavits & Certificate of Svc Encl

ML20049J658
Person / Time
Site:	Skagit
Issue date:	03/06/1982
From:	Rosolie E NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION
To:
References
NUDOCS 8203190096
Download: ML20049J658 (12)

Text

_ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - - - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ -_______ _-

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

.z In the Matter of )

)

PUGET SOUND POWER & LIGHT CO., ) Docket Nos. STN 50-522 PACIFIC POWER & LIGHT CO., ) STN 50-523 WASHINGTON WATER POWER CO., and ) ~

PORTLAND GENERAL ELECTRIC CO. # "

) / /

) & C' (Skagit/Hanford Nuclear ) T' Project, Units 1 and 2) ) g RECam q REQUEST FOR HEARINGS AND AMENDED PETITTON FO u h 7

LEAVE TO INTER 7ENE C CIcck.Id [ /s7 Introduction O w i

[I io By application dated September 18. 1974, Puget Sound Powe Light Company, acting for itself and as agent for Pacific. Power.i&

Light Company, The Washington Water Power Company, Idaho Power Company, and Washington Public Power Supply System applied for construction permits for two boiling water nuclear reactors de-signated as the Skagit Nuclear Power Project, Units 1 and 2.

The proposed facilities were to be located at a site five miles northeast of Sedro Woolley in Skagit County, Washington. By an agreement dated January 23, 1976, ownership shares in the Skagit project were reallocated. Idaho Power' Company and Washington Pu-blic Power Supply System are no longer co-applicants, and Port-land General Electric was added as a thirty percent owner and co-applicant. The Coalition for Safe Power and Forelaws on Board were admitted as intervenors and parties to the proceedingiby Or-der dated May 26, 1976.

go35 On September 26, 1981, Puget Soun'd Power & Light-Company

/

submitted Amendment #23 to the application which relocates the proposed project to the Department of Energy's Hanford Reserva-tion in Benton County, Washington and changes the name of the 8203190096 820306 PDR ADOCK 05000522 8 PDR

project to Skagit/Hanford Nuclear Project. The proposed facility will be located approximately eight miles west of the Columbia River, seven miles north of the Yakima River at Horn Rapids Dam, and twelve miles northwest of the city of North Richland.

On February 5, 1982, a Notice of Receipt of Amended Applica-tion for Construction Permits and Facility Licenses and Notice of Hearing on Amended Application for Construction Permits was published in the Federal Register in the Matter of Puget Sound Power & Light Co., et al., Skagit/Hanford Nuclear Projects, Units 1 and 2, Docket Nos. STN 50-522 and STN 50-523. The notice set March 8, 1982 as the deadline for requests for hearings and a-mended petitions for leave to intervene. Pursuant to 10 CFR 2.714, the Coalition for Safe Power and its members, and Fore-laws on Board and its members (see affidavit) (hereinafter re-fered to as " Coalition") hereby submits its request for hearing and amended petition for leave to intervene.

Description of Petitioner The Coalition is a non-profit citizens organization, founded in 1969 to work for safe energy. Its work includes research and education. The Coalition, through its office'rs and attorneys, has

! represented its members before the Commission as well as state agencies, on questions of nuclear power safety and. licensing, and electric utility rates. The Coalition has been granted full par-ty status in four proceedings before the Commission including the original application for construction permit for the Skagit Nu-clear Projects, Units 1 and 2, application for eonstrucrion ger-

, mit for Pebble Springs Nuclear Plants, Units 1 and 2, and two li-cense amendments for the Trojan Nuclear Power Plant. The Coali-tion has also filed several Show Cause petitions with the NRC.

1 Status of Petitioner The Coalition asserts a continuing intervenor status derived from its admission as a party in the original Skagit Nuclear Pro-ject proceedings. The Coalition for Safe Power and Forelaws on Board were admitted without regard to the location of the pro-posed site. Thus the change in proposed site in the amended ap-plication for construction permit does not alter the original i

status of the organizations.

Amended Interest of the Petitioner The interests of the Coalition are, in large part, predicated on the interests of its members. The Coalition has at least one member residing within a 20-mile radius of the proposed site 4

(e.g. M. Terry Dana), others who reside within a 60-mile radius (e.g. Garth Orkney) and yet others who live throughout Oregon and Washington . (e.g. Linda Larkin) . Affidavits are attached. Members of the Coalition are ratepayers of Puget Sound Power & Light Co.,

Pacific Power & Light Co. and Portland General Electric Co., three of four applicant utilities. Members of the Coalition work, live, recreate and travel in the environs of the proposed Skagit/Hanford site and eat foodstuffs, both dairy, produce and meat, grown and produced in the vicinity potentially impacted upon by the construc-tion and operation of the project. The organization's work, itself, is in part conducted in Richland, Washington approximately sixteen l miles from the proposed site.

How These Interests May Be Affected The above-stated interests of the members and staf f of the Coalition, and thus the Coalition itself as their representative, may be affected by the proposed construction and operation and on-site storage of spent nuclear fuel, of the Skagit/Hanford Project.

The operation of nuclear power plant at the proposed site may en-danger the health of Coalition members due to several factors, the first of which is the routine and accidental releases of low-level ionizing radiation from the plant which will contaninate the air, food and water sources upon which members depend. The safety and well-being of members may be adversly affected by the possibility of a nuclear accident which may damage or destroy their livelihood, homes, other property and happiness. Recreation may be jeopardized by.the project's impact on the water and aquatic life of the Colum-bia River and the surrounding environment. A nuclear accident at the project may af fect the economy of the region. Insurance l

would not adequately cover losses sustained by members of the Coa-

! lition in case of an accident. The proposed plants will place an exessive economic burden on members who are ratepayers of appli-cant utilities.

An Order granting a construction permit in this matter may subject the Coalition to undue risks to health, life and property interests.

Specific Aspects of Subject Matter The Coalition intends to file contentions on the following aspects of the application for construction permit for the Skagit/

Hanford Nuclear Project:

1. Need for Power

2. Alternative Sources of Energy

3. Financial Ability of Applicant

4. Technical Ability of Applicant

5. Geology of the Proposed Site

6. Safety Hazards of the Project

7. Alternative Sites

8. Washington Public Power Supply System Units 4 and 5

9. National Defense

10. Impact of Additional Intake Structures on Columbia River

11. Effect of Thermal Impact on Columbia River

12. Emergency Planning

13. Production and Disposal of Nuclear Wastes from Project

14. Effect of Project on Regional Economy and Agriculture

15. Somatic and Genetic Impact of Radiation Released from Project

16. Cost Benefit Analysis

17. NRC Staff Ability to Adequately Evaluate Project

18. Architect / Engineer Ability to Construct Project in safe manner

19. Applicant and Architect / Engineer ability to conform to NRC Approved QA/QC Proceedure

20. Synergistic Effect Both Upon and By the Proposed Project in relation to the construction and operation of other nuclear fhcilities located at the Hanford Nuclear Reservation

21. Abili*y to Comply with Safety Requirements of TMI Effect of Intervention The Coalition's participation in previous and on-going re-gulatory proceedings is indicative of its ability to assist in the development of a sound record due to its familiarity with the process and the issues, and its access to expert witnesses. The Coalition's participation, for example, in the Trojan Control Building proceedings resulted in additional safety measures be-ing incorporated into plant modification plans. The Coalition's participation in the on-going construction permit application for the Pebble Springs nuclear plants would bring a thorough and con-

temporary understanding to the Skagit/Hanford application.

Conclusions The Coalition for Safe Power and Forelaws on Board, consoli-dated for purposes of this proceeding, having been previously ad-mitted as a party to the originalxSkagit Nuclear Project case, and having herein established a continuing standing of right un-der the Atomic Energy Act of 1954, as amended, the National En-vironmental Policy Act,of 1969, and Chapter 10, Code.of Federal Regulations, Part 2.714, is entitled to receive the hearing it requests on the Puget Sound Power & Light Co., et al. amended application for construction permit, Skagit/Hanford Nuclear Pro-jects, Units 1 and 2, and an Order granting this amended petition for leave to intervene.

Respectfully submitted,

^^JF D Dated this day, the Euggfe Roso)(e, Director sixth of March, 1982. Coalition for Safe Power

1 STATE OF OREGON )

) ss.

2 County of Multnomah )

3 I, Eugene Rosolie, being first duly sworn, do depose and 4 say as follows:

5 1. That I am the Director of the Coalition for Safe Power 6 and its duly authorized representative; and 7 2. That the foregoing petition was prepared under my super-8 vision and direction and that, to the best of my knowledge and 9 belief, it and the facts contained therein are true and correct.

10 Signed:

11 12

[ff.

Eug ge Rosol)d, Director 13 Coafition for Safe Power 14 SUBSCRIBED AND SWORN to before me this sixth day of March, 15 1982.

16 - 1 (3i 17 -

yh,( 0 d) -

Notary Publ\ic for Ore 18 )

My Commission Expir6[gpnf_5L $'ll_

19 20 21 23 23 24 35 26 Page 1 of 1 - AFFIDAVIT

1 STATE Or OREGON )

) ss.

2 County of Multnomah )

3 I, Lloyd K. Marbet, being first duly sworn, do depose and 4 say as follows:

5 1.) That I am Co-Director of F'relaws o on Board and its duly 6 authorized representative; and 7 2) That for the purposes of the amended application for 8 Construction Permit for the Skagit/flanford Nuclear Projects, 9 Forelaws on Board hereby joins in the amended petition for 10 leave to intervene attached hereto.

11 signed

• L y . Marb ;, CoC rector 14 re aw on ard 15 SUBSCRIBED AND SWORN to before me this fifth day of 16 March , 1982.

17 18 y [.3g Notary Public for Oregon 19 My Commission Expires: 2/s/85 20 21 22 23 j

24 25 26 Page 1 of 1 - AFFIDAVIT

- - - - - ~ ~

-'*rer~VAEHT'erny - - )

) ss. '

2 '<>:r.ty o r :s --- )

3 T, ". ! + rr - , beine first dulv 4 <s - rn , clo fiel ose anti say as follows:

4

'i "ha? Y am..a r.emier of the Coalition for Cafe Tower:

6 2 ,, " hat I reside at '

'" '~. --

.....a. .,.4..-... - - - e. e a nc!

S ti ' hat I herel:y authorize the Coalition for ~afe Teser,

' C.rnuch its officers a n t! attorneys, t o r e t.-r e s e n t my interests i n ' r *'r re the 'Juclear "eculatory Commission on any =atter ver-lI c. i n i r.:. to nuclear units 1,0 or .: of the ',ashincton rullic 12 c. . e r T ut f lv e rster, the S'eacit/Hanford nuclear t ro ierts, 13 _ n i . . I arni a anc' the constructir.in or orcration of anv other l' n'elear roser racilite at the !!an rer<! '*uclea r "ese n a ti on .

1- Sitned:

~

._.16 -

17 /$ J/.OM) w -

m t ; -c.. + -, . . . - - - . . c t .- ,,,s.r e nre -e 'his

. '.' - d: y e r ,

n, e' :a--

. . t o. : P. .

M' A t.n m-3 e [ , e_

n t e.: y : n ' 't i c Ft. r

• a s h i r t t c :- ,

.2 y Cc~eis-inn x: i r e s : /r 2 7'. r 3

~

_a 3

16 P.gr

...-: . rrr ,\ ! - e.---'-----

... . ... .. . . =.

- ~

' -- ~

't em Tr~ nr ~ti ASHTNt* TON )

2 County of /f$/$k

• 3 T,

~

nA077/ . RN W lf, beine fi rst uulv 4 worn, do clerose and say as f ollows : V 5 ' l._! hat T an_.a_ =emi:er o f the Coalition for Safe Tower; 6 2) That I reside at M[ M//9/d+t ,

7 A C/r?fA . Y ., h$0/  : and

/ /

S t V' ha tI herely authori re the Coalition for Sa fe Tower, 9 thrnuch its officers and attorneys, to rerresent my int ~ rests 10 Fe' ore the '?uclear "cculatory Commission on any matter rer-11 tai ni nt. to nucle..r units 1,7 or .: of t.he hashing; ton fullic 12 ' owe r c ui riv System, the S'<ac i t/Hanfor d nuclea r rrojects, 13 u n i t s 1 and ' and the construction or areration of anv other 14 nnel ea r rower facility at the Hanford "uclear Reservation.

15 Si tc ned :

_ _ _ 16 _ _ _ _ _ _ __

= -

_ ;- _m

- ,Y

• 1.,. - si A ,

gg g t t e r T I ~', '

- e' r'": t c, 5ero r t. -e t h i s. A 9' dav o ,

r'~~ !

l" /1'd4 v ae v , 19 1 7

o

. r - /-

_o }

Q H2 *1.L'hCij . .

Md'M?fd/J' Vctarv Fu' lic fo r ashi nc ton 22 v y Commisuion Txiires: 3/t.:2 /g5 23

a 25 26 pa.4,; i ,, r ! _ . r r :wrr CC / "::' ec' c-"E 'O' .~t

. I w : .

F R. '.M .: . C : . _ . ' . .4

1 STAC OF OREGON

)

) ss.

2 County of !!ultnomah )

3 I, Linda J. Larkin, being first duly sworn, do depose and 4 say as follows:

5 1. That_I am a member of the Coalition for Safe Power; 6 2. That I reside at -vy.i 9 '. T f i[' W N '

• 7 i '.7du

('

L 'G li )  ; and 8 3. That I hereby authorize the Coalition for Safe Power, 9 through its officers and attorneys, to represent my interests 10 before the Nuclear Regulatory Commission on any matter per-11 taining to the Trojan Nuclear Poeer Plant, Washington Public 12 Power Supply System Units 1,2,3,4 cnd 5, the Pebble Springs 13 Nuclear Projects, Units 1 and 2,~the 5!agit/Eanford Nuclear 14 Projects, Units 1 and 2 and the constructicn or operation of 15 any other nuclear facility in the states of Oregon and Washing-16 ton. _ _. _ _ _ _ .

17 Si 'ed: 1

'\ Il' 18 ,- 1' J

19 / ' g1.;- .x .

20 SUBSCRIBED AND SWORN to before me this sixth day of March, 21 1982.

22

-m, 20

. Akbn P !? )

34

^

Notary Public for Oregon My Commission Expires: 2/3/a5*

25 26 Page 1 of 1 - AFFIDAVIT COAUTION FOR SAFE PC'..n SUITE 527 403 5 w : :

PCRTLAND. oEC.y ;:4

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIS3 ION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD' ,

In the Matter of )

PUGET SOUND POWER & LIGHT CO., ) Docket Nos. STN 50-522 PACIFIC POWER & LIGHT CO., ) STN 50-523 WASHINGTON WATER POWER CO., and )

PORTLAND GENERAL ELECTRIC CO. )

)

(Skagit/Hanford Nuclear )

Project, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that on March 6, 1982, the Coalition for Safe Power's REQUEST FOR HEARINGS AND AMENDED PETITION FOR LEAVE TO INTERVENE was served upon the parties listed below by depositing copies thereof in the United States mail with proper first class postage.

Secretary of the Commission U.S. Nuclear Regulatory Commission Washington D.C. 20555 Attn: Docketing & Service Branch Executive Legal Director U.S. Nuclear Regulatory Commission Washington D.C. 20555 Mr. F. Theodore Thomsen Perkins, Coie, Stone, Olsen & Williams 1900 Washington Building Seattle, Washington 98101 Signed:

. k Dated this day, the Eugerf Rosolife, Director sixth of March, 1982. Coalftion fof Safe Power